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    <title>1974 (12) TMI 21 - CALCUTTA High Court</title>
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    <description>A loan or advance by a closely held company to its shareholder is treated as deemed dividend under section 2(6A)(e) of the Indian Income-tax Act, 1922 to the extent of the company&#039;s accumulated profits. The provision operates on the whole payment made to the shareholder, not merely on a proportionate part referable to shareholding. Accordingly, where the loan falls within the section and accumulated profits are sufficient, the full amount of the loan is taxable as dividend up to the available profits. On the stated facts, the loan was less than the accumulated profits and was therefore assessable in full as dividend.</description>
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    <pubDate>Thu, 05 Dec 1974 00:00:00 +0530</pubDate>
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      <title>1974 (12) TMI 21 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39201</link>
      <description>A loan or advance by a closely held company to its shareholder is treated as deemed dividend under section 2(6A)(e) of the Indian Income-tax Act, 1922 to the extent of the company&#039;s accumulated profits. The provision operates on the whole payment made to the shareholder, not merely on a proportionate part referable to shareholding. Accordingly, where the loan falls within the section and accumulated profits are sufficient, the full amount of the loan is taxable as dividend up to the available profits. On the stated facts, the loan was less than the accumulated profits and was therefore assessable in full as dividend.</description>
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      <pubDate>Thu, 05 Dec 1974 00:00:00 +0530</pubDate>
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